LABOTEC DATA PROTECTION AND PRIVACY POLICY

1. INTRODUCTION

Respecting and protecting your privacy and Personal Information is very important to Labotec. It is also a Constitutional right and good business practice requirement which we take very seriously. In line with the 8 Conditions for Lawful Procession of Personal Information as set out in the Protection of Personal Information Act no 4 of 2013 (the Act), we –
• Accept joint responsibility and accountability with you to responsibly manage and protect your Personal Information when providing our services and solutions to you;
• Undertake to collect and process only such Personal Information in connection with and for the purposes of the provision of the Products and/or Services offered, to conclude the necessarily related agreements and consider the legitimate legal interests of everyone concerned, as required by the Act. We will at all times respect your right to withdraw your consent for the processing of your Personal Information;
• Undertake to only use your Personal Information for the purpose for which the information is essential to enable us to assist you or provide products and services, to you;
• Undertake not to share or further process your Personal Information with anyone or for any reason if not required for assisting you with your solutions or as required in terms of legislation or regulations;
• Undertake to take reasonably practicable steps to ensure that information is complete, accurate, not misleading and, where necessary, is updated;
• Undertake to be open and transparent on the nature, extent and reasons for processing Personal Information;
• Undertake to safeguard and protect your Personal Information in our possession according to generally accepted security practise
• Undertake to freely confirm what Personal Information we hold of you, to update and rectify the Personal Information upon request and to keep it for no longer than required.
By providing us with your Personal Information, you agree to this Policy and authorise us to process such information as set out herein and you authorise Labotec and associated entities or third parties (where applicable) for the purposes set out herein. We will not use your Personal Information for any other purpose than that set out in this Policy and we will take the necessary steps to secure the integrity and confidentiality of Personal Information in our possession and under our control by taking appropriate and reasonable measures to prevent loss of, damage to or unauthorised destruction of your Personal Information and to prevent the unlawful access to, or processing of Personal Information.

2. HOW WE USE COLLECTED INFORMATION

We, or the entities who provide or assist with the solutions you required (if any), need to collect, use and keep your Personal Information as prescribed by relevant legislation and regulations and for reasons such as:

• To provide all relevant services in accordance with your relationship with us as set out in the relevant agreement or arrangement and to maintain our relationship;
• To respond to your queries;
• To confirm and verify your identity or to verify that you are an authorised user for security purposes;
• To comply with all legislative or regulatory requirements related to services provided to you by us;
• To fulfil our contractual obligations to you, for example to ensure that invoices are issued correctly, to ensure that all payments made to you is done correctly, to communicate with you and to carry out instructions and requests, and for ensuring you are able to access our premises when required;
• For any other operational purposes required to assist you with the solutions and services that you require from us;
• To communicate with you any product news, promotions, industry updates in the form of a company newsletter or other electronic marketing media from which you may unsubscribe from at any time you deem necessary;
• To comply with our legal obligations to you, for example health and safety obligations while you are on any of our premises, or to a third party;
• In connection with possible requirements by the Information Regulator or other Government agencies allowed by law, legal proceedings, or court rulings. We will collect personal identification information from you only if you voluntarily submit such information to us

3. INFORMATION WE COLLECT

3.1 When you visit our webpage

You are free to explore our website without providing any information about yourself. We request that you provide personal information about yourself if you request further product or service information, quotations or request for a direct contact by an sales representative or product manager , . Non-personal Navigational Information is collected when interacting with our website.

3.2. Personal identification information

We only use personal data with your express consent, based on your actions and behaviour, or if there are legal requirements. We collect personal identification information from you when you visit our site, and in connection with other activities, quote requests, services, features or resources. You may be asked for, as appropriate, name, email, company physical address, mailing address, phone number. We will collect personal identification information from you only if you voluntarily submit such information to us. You can always refuse to supply personally identification information, except that it may prevent you from engaging in certain business related activities. We may collect personal data about you from third parties (such as Google), advertising partners, public sources, and social networking sites. Such information may include personal data as part of your profile on a social network, especially if you allow these partners to provide us with this information in accordance with its rules.

3.3 Non-personal data

We collect non-personal identification information about you when you interact with our website. Non-personal identification information may include the type of computer you are using, the browser type, IP address, geographical location, referral source, length of visit and pages viewed.

4. BUSINESS ACTIVITIES FOR WHICH PERSONAL INFORMATION IS PROCESSED

• Providing Professional Products and Services as per our supplier and client mandates and agreements;
• Recruitment and Employment purposes
• Financial information related to the management of customer and supplier accounts
• Administering, managing and developing our businesses and services;
• Security, quality, and risk management activities;
• Third parties within and outside the borders of South Africa to assist us in the performance of services related to the processing of your personal data. For example, we may use third parties to send emails, host the website, operate the various features available on the site, and analyse data.

We only transfer the amount of personal data that is required for the service providers we use to provide the services on offer. This will be done in very limited circumstances and in strict adherence of all requirements of the Act and other relevant legislation.

5. SHARING OR TRANSFER OF PERSONAL INFORMATION

Our employees will have access to your Personal Information to administer and manage our services and internal business processes. In general, we do not share your Personal Information with third parties (other than service providers acting on our behalf) unless we have a lawful basis for doing so.

6. INFORMATION SECURITY

We are legally obliged to provide adequate protection for the Personal Information we hold and to stop unauthorised access and use thereof. We will, on an ongoing basis, continue to review our security controls and related processes to ensure that your Personal Information remains secure. Generally accepted standards of technology and operational security have been implemented to protect information from loss, misuse, alteration, or destruction. All Labotec employees are trained on information security and are required to keep Personal Information confidential and only authorised persons have access to such information. When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that personal information that we remain responsible for, is kept secure.

7. SUBCONTRACTING

7.1. Labotec may not subcontract the performance of any of its obligations under this Agreement without the customers prior written consent having been obtained. All references to the Supplier’s Staff shall be deemed to include the employees of any subcontractor of the Supplier.
7.2. In the event that the customer agrees to the Supplier subcontracting certain or all of the Supplier’s obligations, the Supplier must only do so by way of a written contract with the subcontractor which contract must impose the same obligations on the subcontractor as are imposed on the Supplier in terms of this Agreement insofar as the Processing of Personal Information by the subcontractor is concerned.

8. CROSS-BORDER DATA TRANSFER

8.1. It is hereby recorded and agreed that in order for the Supplier to be able to fulfil its obligations in terms of the Agreement, it may be necessary for the Supplier to transfer Personal Information to a sub-processor for Processing for the purposes agreed to in the Agreement and in this Agreement.
8.2. In the event of such cross-border transfer and cross-border Processing, the Supplier hereby warrants and undertakes in favour of the customer that:
8.2.1. it shall procure the sub-processor’s compliance with all the obligations of this Agreement insofar as the Processing of Personal Information by the sub-processor is concerned;
8.2.2 the Supplier shall at all times be responsible to the customer for fulfilment of all the Supplier’s obligations under the Contract and remain the customers sole point of contact regarding the Products and/or Services, including with respect to payment;
8.2.3. it shall procure that the sub-processor abides by all the applicable data and privacy and protection legislation within the country wherein the Personal Information will be Processed;
8.2.4. it shall ensure that the sub-processor has implemented the appropriate technical and organisational security measures in the relevant jurisdiction in which the Personal Information is being transferred.

9. RETENTION OF PERSONAL INFORMATION

We shall only retain and store Personal Information for the period for which the data is required to serve its primary purpose or a legitimate interest or for the period required to comply with an applicable legal requirement, whichever is longer.

10. YOUR RIGHTS

You can find out what personal data we have about you by emailing us at privacy@labotec.co.za Tell us if you want to exercise your right to view data, correct data, delete data or prohibit further use. Please enter your contact details. You can unsubscribe from our marketing communication list at any time. Please use the ‘unsubscribe’ function or contact privacy@labotec.co.za You can also regulate the use of cookies in your browser and decide whether you only accept cookies after consultation, or completely deactivate them, by selecting the appropriate setting.

11. CONTACTING US

If you have any questions about this Privacy Policy or our treatment of the information you provide us, please contact us by email privacy@labotec.co.za or by mail to:
Labotec (Pty) Ltd
P.O. Box 6553
Halfway House
Midrand
1685